V I R G I N I A :
IN THE GENERAL DISTRICT COURT OF ARLINGTON COUNTY
CIVIL DIVISION
RAM AVRAHAMI, :
:
Plaintiff, :
:
v. : Civil Action No. 95-7479
:
:
U.S. NEWS & WORLD REPORT, INC., :
:
Defendant. :
PLAINTIFF REQUEST FOR ADMISSION
COMES NOW the Plaintiff, Ram Avrahami, by counsel, and
propounds the following requests for admission to Defendant U.S.
News and World Report ("U.S. News"):
1. That pursuant to a list exchange agreement dated March 5,
1995, between Defendant U.S News and the Smithsonian Magazine, on
or about March 24, 1995, Plaintiff Ram Avrahami's name and address
was transferred to the Smithsonian Magazine as a part of a mailing
list.
2. That in exchange for the mailing list referred to above
in paragraph 1, U.S. News received from the Smithsonian a
comparable mailing list and/or the equivalent commercial value.
RAM AVRAHAMI
By Counsel
Law Offices of Jonathan C. Dailey
1050 17th Street, N.W., Suite 600
Washington, D.C. 20036
(202) 496-1290
By: /s/
Jonathan C. Dailey (#37442)
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